ON PETITION FOR WRIT OF CERTIORARI FROM AN ANONYMOUS FANTASY BASEBALL LEAGUE

Decided July 25, 2012
Cite as 4 F.J. 150 (July 2012)

Factual Background

An anonymous fantasy baseball league (hereinafter referred to as “the league” is a 14-team mixed AL/NL keeper league comprised of two divisions of seven (7) teams each where the top three (3) teams in each division earn a playoff berth. Teams are permitted to maintain up to fourteen (14) players during each off-season. It is unknown whether players are signed to contracts or if there are any restrictions on how long a player may be retained.

It is unknown whether the league is rotisserie or points based. The Court presumes it is a head-to-head league given the commissioner’s filed with the Court references one team being “five games out of the last playoff spot.”

The Court’s forthcoming decision is based on the information provided in the case submission by the league commissioner.

Procedural History

A controversial trade was made between two teams in the league. Wookie Invasion traded Andre Ethier (OF-LAD) and Lance Berkman (1B/OF-STL) to the Pumas in exchange for Sergio Santos (RP-TOR) and Trevor Bauer (SP-ARZ). Wookie Invasion is currently in last place in its division. The Pumas are currently in 5th place in their division and five games out of the final playoff spot.

It is alleged that Wookie Invasion has a personal issue with Pinetar Ponies, the 3rd place team. After some league members questioned the validity and rationale behind the trade, Wookie Invasion responded via email to the entire league that he “100% traded in order to help the Pumas catch the Pinetar Ponies.”

The league commissioner seeks an opinion from the Court whether this trade should be approved or rejected.

Issues Presented

(1) Was this trade executed as a result of collusive conduct between Wookie Invasion and the Pumas?

(2) If there is no collusive conduct present, should the trade made between Wookie Invasion and the Pumas be approved?

Decision

The analysis of this case involves two elements. First, we must determine if there is any collusion involved between the teams making the underlying trade. Once that has been determined, we can enter into a discussion about the actual merits of the trade and the players involved.

I. WAS THIS TRADE EXECUTED AS A RESULT OF COLLUSIVE CONDUCT BETWEEN WOOKIE INVASION AND THE PUMAS?

The statement made by Wookie Invasion regarding his motivation for making this trade is worrisome. It is not uncommon for people to have personal issues or conflicts within the confines of a fantasy league. The very nature of competition can foster animosity, or a personal issue can manifest itself into the social atmosphere of a fantasy league. What the Court seeks to avoid is allowing these issues to undermine the integrity of the entire league.

On its face, there is an appearance of impropriety because Wookie Invasion has openly admitted that he is motivated to make this trade for the sole purpose of improving the Pumas’ chances of catching the Pinetar Ponies in the standings. What we must look at closely is whether the Pumas have conspired with Wookie Invasion to facilitate this deal and, in exchange, offered a tangible benefit to Wookie Invasion.

Collusion is defined as a secret agreement or conspiracy especially for fraudulent or treacherous purposes. SeeSteel Curtain v. Rusty Trombones, 3 F.J. 201, 203 (November 2011). When presented with allegations or suspicions of collusion, the Court will look at the evidence in the light most favorable to the accused. This is because acts of collusion within a fantasy league are one of the most serious fantasy sports crimes that can be committed and can undermine the integrity of a league more so than almost anything else. Team Zero v. Samcro Reaper Crew, 3 F.J. 177, 179 (October 2011).

From the Pumas perspective, they are clearly receiving a windfall in this trade based on present-day value. The additions of Ethier, one of the top outfielders in the league, and Berkman are indisputably huge improvements over Santos and Bauer for the 2012 season. Santos has been out since April and recently underwent season-ending shoulder surgery. Any value he has is purely based on projections and long-term planning for when he returns. Bauer, one of the top pitching prospects in baseball, did not have a successful stint at the major league level earlier this year. He is currently in the minors and likely won’t have much fantasy impact for the remainder of the 2012 season.

The record is devoid of any indication that the Pumas sought to take advantage of Wookie Invasion’s personal vendetta against the Pinetar Ponies. All indications are that Wookie Invasion looked to make a deal with a team in a position to knock the Pinetar Ponies out of a playoff berth. The Court will refrain from making a judgment on the maturity or sensibility of such a desire. However, it seems apparent that the Pumas merely were the innocent beneficiary Wookie Invasion’s intentions.

Without a confession or some form of written proof, the Court will rely on circumstantial evidence and weigh the totality of the circumstances to determine if collusive conduct is present. John Doe v. Richard Roe, 3. F.J. 197, 200 (October 2011). Here, there is no confession from the Pumas. There is no indication that the Pumas consented to any sort of plan to purposefully undermine the integrity of the league. They simply accepted a trade that was proposed to them and that improved their team for the current season. SeeRoad Runners v. Urban Achievers, 3 F.J. 47, 50 (June 2011) (holding that fantasy baseball teams are not obligated to shop players around for a more advantageous deal solely to appease skeptical league members).

There is no indication whatsoever that the Pumas and Wookie Invasion agreed to a monetary share of any prize money that is potentially won. There is also no indication that an agreement was reached for future trades to be made as compensation. Despite it being overtly obvious what Wookie Invasion’s motive was, there is no evidence to support the contention that the Pumas shared such Machiavellian intent. Rather, they agreed to a trade that benefited their team. Based on the foregoing, the Court concludes that the Pumas did not conspire with Wookie Invasion in an act of collusion.

II. IF THERE IS NO COLLUSIVE CONDUCT PRESENT, SHOULD THE TRADE MADE BETWEEN WOOKIE INVASION AND THE PUMAS BE APPROVED?

The Court typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades. People pay money to participate in fantasy leagues, and generally they should be afforded the freedom to manage their team accordingly. Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness. See4 Ponies v. Carson City Cocks, 3 F.J. 13 (May 2011).

It is well documented that there is a different analysis of trades in a keeper league as opposed to a non-keeper league. A trade that may look facially uneven or lopsided could easily pass muster in a keeper league. Trades made between teams in a keeper league need to be analyzed by other factors besides merely comparing statistics. Grave Diggers vs. Chilidogs, 4 F.J. 5, 8 (January 2012). These other factors include salary cap flexibility, contractual status of players, and long-term planning at the expense of the current season. Smittydogs vs. Moneyball, 1 F.J. 32, 33 (June 2010); Winners vs. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011) (holding that team owners in keeper leagues with no hope of contending in the current season must make critical roster management decisions of whether to trade established players to help build for the future).

The Court will evaluate the objective merits of a deal and ensure that the integrity of the league is maintained. SeeVictoria’s Secret vs. C-Train, 2 F.J. 32, 35 (October 2010). The Court will not undermine a fantasy owner’s ability to manage his/her team unless a deal is unfair or inequitable, ripe with collusion, or not in the best interests of the league. Whether a trade is objectively intelligent or popular will not be part of the analysis. 4 Ponies vs. Beaver Hunters, 3 F.J. 26, 27 (June 2011). The virtue of a trade is measured in both quantifiable criteria and subjective needs of the teams involved. Carson City Cocks vs. Stud Muffins, 3 F.J. 23, 24 (May 2011).

At first glance, the trade of Andre Ethier and Lance Berkman in exchange for Sergio Santos and Trevor Bauer looks inequitable based on present-day value. None of the players involved in this trade are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are based on their statistics and name recognition. SeeSteelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

Ethier is the best player in this trade. Through July 24, 2012, he is batting .294 with 11 homeruns, 61 RBI and an OPS of .853. While it is unlikely he will reach 30 homeruns, his run production and batting average should improve with the Dodgers’ recent acquisition of Hanley Ramirez who will likely bat ahead of Ethier in the lineup.

Berkman had a renaissance season in 2011. While it was doubtful he would replicate that this year, he hasn’t been on the field much to try. Berkman has been hobbled by injuries all season which has limited him to only 21 games. He recently was hit by a pitch on the same knee that was operated on earlier in the year. While he is not expected to miss much time as a result, he is clearly not the same player he was last year as his bat speed has decreased and he cannot generate the same power out of his legs.

Bauer, one of the top pitching prospects in all of baseball, had a disappointing stint with the Diamondbacks. He only pitched four games, winning just one while accumulating a disastrous 6.06 ERA and 1.65 WHIP. However, this was a small sample after Bauer only had a handful of starts at Triple-A. With more seasoning, he will be a fixture in Arizona’s starting rotation in 2013.

Santos was acquired by the Blue Jays this past offseason to be their new closer. However, he sustained a shoulder injury in April and had to undergo season-ending surgery. All indications thus far are that he will be ready for the 2013 season and should assume Toronto’s closer role once again. When healthy, he could be in line for 30 saves next year with an improving Toronto team that will get half of its starting rotation back by then.

When analyzing the fairness and equity of a trade, the Court will consider each team’s individual needs to assess whether the trade subjectively made sense from each team’s perspective. SeeCajon Crawdads vs. Carson City Cocks, 1 F.J. 41, 42 (June 2010) (upholding a trade for Jason Bay because of the Carson City Cocks’ desperate need for a starting outfielder due to the demotion of Cameron Maybin). The Court is unaware of each team’s respective rosters. Therefore, we cannot draw any conclusions or make any comparisons to the roster needs of either team. However, the Pumas, only five games out of the final playoff berth, are clearly looking to make a run for this season. The acquisitions of Ethier and Berkman are indicative of improving his team with a “win now” mentality.

Conversely, Wookie Invasion is in last place with no hopes of competing this year. When a team owner in a keeper league no longer has any hope for contending in the current season, he must make a critical roster management decision of whether to trade off established players. SeeWinners v. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011). Granted his underlying motivation for helping the Pumas overtake the Pinetar Ponies has to be taken into account. But the fact remains that Santos and Bauer do have long-term value despite offering nothing in compensation for the current season.

A trade will be rejected when the Court cannot objectively ascertain any benefit to one of the teams and the net result in no way makes a team better now or in the future. Los Pollos Hermanos v. Little Stumps, 3 F.J. 192, 195 (October 2011). While this trade is completely one-sided for the 2012 season, it does have projected value for next season and beyond. Because of the projected value Bauer and Santos have, this deal cannot be considered a “dump.” Additionally, while Ethier is a very good player, he is not at the same level as someone like Miguel Cabrera or Ryan Braun.

Based on the foregoing reasons, the Court hereby decides that the subject trade should be approved. However, the personal vendetta between Wookie Invasion and Pinetar Ponies needs to be addressed by the commissioner. While this controversial trade should be approved, it could potentially lead to a slippery slope that could undermine the integrity of the league.